Oregon Wild v. United States Forest Service

CourtDistrict Court, D. Oregon
DecidedApril 4, 2025
Docket1:22-cv-01007
StatusUnknown

This text of Oregon Wild v. United States Forest Service (Oregon Wild v. United States Forest Service) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oregon Wild v. United States Forest Service, (D. Or. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

EUGENE DIVISION

OREGON WILD, an Oregon nonprofit Case No. 1:22-cv-01007-MC corporation; and WILDEARTH GUARDIANS, a New Mexico OPINION AND ORDER nonprofit corporation,

Plaintiffs, v.

UNITED STATES FOREST SERVICE; MICHAEL RAMSEY, in his official capacity as Lakeview Ranger District Ranger; JEANNETTE WILSON, in her official capacity as Silver Lake Ranger District Ranger; RANDY MOORE, in his official capacity as Chief of the U.S. Forest Service; and THOMAS VILSACK, in his official capacity as Secretary of Agriculture,

Defendants.

MCSHANE, Judge:

Before the Court is Plaintiffs Oregon Wild and WildEarth Guardians’ Motion for Leave to Amend/Supplement the Complaint. ECF No. 55. Plaintiffs, pursuant to Federal Rule of Civil Procedure 15(a)(2), move to supplement the allegations within the complaint, add a third claim, and join a third plaintiff. Defendants oppose, arguing that the proposed amendments are dilatory, prejudicial, and futile. Defs.’ Resp., ECF No. 57. Because the Court finds that the Plaintiffs’ amendments are timely and do not cause undue prejudice to the Defendants, the Court GRANTS Plaintiffs’ Motion. BACKGROUND On July 12, 2022, Plaintiffs Oregon Wild and WildEarth Guardians filed their original complaint, seeking declaratory and injunctive relief under the National Environmental Policy Act (“NEPA”) and the Administrative Procedure Act (“APA”). Compl. ¶¶ 1, 6, ECF No. 1. Plaintiffs challenged the Forest Service’s authorization of three logging projects under a categorical

exclusion, CE-6, arguing that an environmental impact statement or an environmental assessment was required by the agency. Id. at ¶ 5. Plaintiffs alternatively claimed that CE-6 does not apply to activities of the type and scale authorized by the projects, but if it does, then CE-6 is unlawful as applied. Id. at ¶¶ 5–6. On the first claim, this Court granted summary judgment in favor of Defendants, finding that CE-6 does apply and its use was not in violation of the APA. Op. and Order 13, ECF No. 40. On the second claim, this Court granted summary judgment in favor of Defendants, finding that the claim was time-barred under the six-year statute of limitations for as-applied challenges set forth in Wind River Mining Corp. v. United States, 946 F.2d 710 (9th Cir. 1991). Id. at 17.

On August 28, 2023, Plaintiffs filed their Notice of Appeal. ECF No. 45. The Ninth Circuit affirmed summary judgment as to the first claim, holding that Defendants did not violate the APA. Or. Wild v. U.S. Forest Serv., No. 23-35579, 2024 WL 4286965, at *1 (9th Cir. 2024). However, the Ninth Circuit vacated and remanded the second claim, concluding that the Supreme Court’s recent decision in Corner Post, Inc. v. Bd. of Governors of the Fed. Rsrv. Sys., 603 U.S. 799 (2024) likely abrogated Wind River’s rule. Id. at *3. On remand, this Court is directed “to apply Corner Post in the first instance to determine whether [claim two] is time- barred.” Id. Plaintiffs now move, over Defendants’ objections, to amend and supplement their complaint. Pls.’ Mot. 1; Defs.’ Resp. 1. Plaintiffs seek to add “GO Alliance” as a third plaintiff; add a facial challenge to CE-6 as a third NEPA claim; and amend the pleadings to omit unnecessary claims and reflect the intervening changes in law and recent factual developments. Pls.’ Mot. 4.

DISCUSSION “Absent a mandate which explicitly directs to the contrary, a district court upon remand can permit the plaintiff to ‘file additional pleadings, vary or expand the issues.’” Nguyen v. United States, 792 F.2d 1500, 1502 (9th Cir. 1986) (quoting Rogers v. Hill, 289 U.S. 582, 587– 88 (1933)). Lower courts are unquestionably obligated, under the “rule of mandate,” to execute a mandate’s terms and abstain from reconsidering matters already determined by the appellate court. San Francisco Herring Ass'n v. Dep't of the Interior, 946 F.3d 564, 574 (9th Cir. 2019) (quoting United States v. Kellington, 217 F.3d 1084, 1092 (9th Cir. 2000)). “[A]ny issue not expressly or impliedly disposed of on appeal,” however, is left to the district court to decide.

Nguyen, 792 F.2d at 1502; see also Hall v. City of Los Angeles, 697 F.3d 1059, 1067 (9th Cir. 2012). Here, the Ninth Circuit vacated summary judgment on claim two and remanded with express directions to apply the Corner Post framework to determine if the as-applied challenge is time-barred. The mandate did not address the possibility of amendments, nor was there indication of an intent to deny amendments made in the ordinary course of litigation that seek to raise a parallel claim or add a new plaintiff. Rather, the mandate implicitly authorizes this Court to revisit the merits of claim two, should it find that the claim is no longer time barred. The Court therefore determines that the Ninth Circuit’s mandate does not prevent Plaintiffs from seeking leave to amend. Where amendment is not explicitly or impliedly precluded, “the decision whether to allow leave to amend is within the trial court’s discretion.” Nguyen, 792 F.2d at 1503. Under Rule 15, district courts are to “freely give leave [to amend] when justice so requires.” Fed. R. Civ. P. 15; see also DCD Progs., Ltd. v. Leighton, 833 F.2d 183, 185–86 (9th Cir. 1987).1

Absent a strong showing of bad faith, futility, undue delay, or prejudice, leave to amend should be granted. Eminence Cap., LLC v. Aspeon, Inc., 316 F.3d 1048, 1052 (9th Cir. 2003). Defendants oppose the amendments, arguing (1) that allowing GO Alliance to join claim two would be futile; (2) that Plaintiffs inexcusably delayed in bringing claim three and adding GO Alliance; and (3) that the amendments are prejudicial because they would expand the remand proceedings beyond the limited scope of the Ninth Circuit’s mandate and contravene prior pleading deadlines. Defs.’ Resp. 8–18. The Court cannot agree. First, Defendants do not allege, nor does the Court find, evidence of bad faith by the Plaintiffs. Likewise, Defendants’ futility argument is moot, as Plaintiffs have repeatedly

expressed that GO Alliance seeks only to join claim three, not claim two. Pls.’ Reply 11, n.1, n.4, ECF No. 58. On the question of Plaintiffs’ timeliness, the Court does not find that Plaintiffs were dilatory in amending as they have. Plaintiffs’ third claim was initially time-barred. With the new playing field created by Corner Post, Plaintiffs promptly submitted a 28(j) letter to the Ninth Circuit. When the Ninth Circuit issued its mandate, Plaintiffs promptly moved to amend. There is no undue delay under these circumstances and, even so, undue delay by itself is insufficient grounds for denial. DCD Progs., Ltd., 833 F.2d at 186.

1 The standard under Rule 15(a) for a motion for leave to amend also governs a motion for leave to supplement a pleading. Nat’l Mgmt. Servs., Inc. v. Qwest Dex, Inc., No. 01-1772, 2004 WL 7338477, *2 (D. Or. 2004).

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